As of December 26, 2024, the nationwide injunction against implementing the Corporate Transparency Act (CTA), initially granted by the U.S. District Court for the Eastern District of Texas on December 3, 2024, has been reinstated. While a panel from the U.S. Court of Appeals for the Fifth Circuit temporarily lifted the injunction on December 23, 2024, another panel effectively reinstated it just three days later.
Currently, reporting companies are not required to comply with the CTA. However, with the U.S. Department of Justice likely to appeal, the situation remains fluid, and businesses should be prepared for potential changes.
While the injunction is in effect, companies should:
- Evaluate Reporting Requirements: Determine whether they qualify as a reporting company or are exempt under the CTA.
- Identify Beneficial Owners: For those not exempt, identify beneficial owners and gather the necessary information.
Preparation is essential if the injunction is lifted or a ruling upholding the CTA is issued. FEAGANS LLC continues to monitor developments in this case and any further updates from FinCEN.
If you have any inquiries regarding your obligations related to the CTA, please reach out to FEAGANS LLC. We are here to provide support and clarity regarding your compliance obligations under the CTA.
